Text For Citation: 02 Item/Group: 002 Hazard: ERGONOMIC

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The %% employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees who sustained cumulative trauma disorders (CTDs) were exposed to increased risk of aggravation to exiting injuries and illnesses and developing further injuries and illnesses: a) Where ther were 94 cases of CTD's of which 25 cases involved surgery, during the period from January 1, 1987 through September 6, 1989, and the medical management program was deficient in the following areas: 1) There was no formal educational process for management and employees regarding CTD's. 2) There were no written procedurs for the handling and disposition of CTD cases as they arise. 3) There was no on-site nurse or physician who could handle multiple responsibilities including ergonomic assessment of CTD symptoms, first-aid situations and OSHA injury and illness recordkeeping. 4) There was no pre-employment medical screening program for CTD's. 5) There was no exercise program to emphasize flexibility and stretching to help limit CTD's. 6) Employee breaks were infrequent and thus not conducive to preventing CTD's. 7) There were no regularly scheduled meetings invovling interactions between management and employees to address safety and health issues. 8) There was no program for the early detection of CTD's. 9) There was no tracking program (statistical ergonomic records) for monitoring CTD trends. 10) Employees returned to their former jobs following medical treatment and time off for CTD's without the work environment having been modified to minimize the risk of reocurrences. In addition, there were no follow-up procedures to assess whether the employee's condition had changed. While ultimate responsibility for correcting the hazard rests with the employer given his superior knowledge of the operation, feasible and acceptable abatement methods to correct this hazard may include, but are not limited to: 1) Implement a comprehensive written compliance program including priorities for early detection, treatment, job reassignment and follow-up of CTD. The program shall include provisions for prompt recognition and evaluation of employee symptoms, scheduling procedure for employees to help them recover from CTD and surgery, and assurance of management's implementation of medical restrictions. This program shall be part of the overall written plan describing how and when each element will be accomplished. The overall plan shall be reviewed and updated quarterly to ensure goals are being met or to identify changes needed. 2) Implement a written program to identify employees developing CTD, and work methods and work stations causing CTD. a) Design a baseline symptoms survey to measure, on a plant-wide basis, the extent of employee awareness of their symptoms of work-related disorders. The results of which may be collected and processed by automated process. b) Conduct a plant wide symptoms survey and repeat it annually to detect any significant change in the incidence, scope, and/or location of reported symptoms. This survey will also help to determine the effectiveness of the overall medical management program and employees job rotation program as related to ergonomics. c) Each quarter the employer shall review medical facility sign-in logs, OSHA-200 Forms, and individual employee medical records to monitor CTD trends in the plant. This analysis shall be completed in addition to the "symptoms survey" in order to monitor trends continuously and substantiate information obtained in the annual symptoms survey. d) Compile, and keep current, a written catalog of job activities for each work position. The activity performed at the work position should be described and stressors identified as they affect specific parts of the body such as: physical stress, forces required to exert, posture (twisting, turning, lifting, bending, misalignment of body parts), workstation hardware, repetitiveness of activity, lack of breaks, tool design, training, employee turn over. A current catalog is very necessary to establish any "light duty" work positions and have an effective job rotation program. e) Consideration shall be given to the provision of an on-site nurse, part time or full time, who could handle multiple responsibilities including maintenance of injury and illness records, handling first aid treatment, assessment of ergonomics complaints and physician referrals. 3) Implement a written medical management protocol for CTDs. The employer shall ensure that all physicians and nurses shall be qualified and trained to use this protocol which will include the following: a) A standardized physical examination, medical history and recording form. The examination will at least include inspection, palpation and range of motion testing and various applicable maneuvers, i.e., Tinel's test, Phalen's test, and Finkelstein's test. b) Specific protocols for the treatment of employees with positive physical signs on examination as well as those with symptoms but no physical signs shall be written and followed. Any symptoms with numbness or crepitus shall be referred to a physican. In addition, employees with positive Tinel's, Phalen's or Finkelstein's tests shall also be referred for physician evaluation. c) Schedule re-evaluation in no less than three days after initial report of condition. If the condition worsens further, medical management should not be undertaken without concurrent efforts to reduce the physical stresses of the job by such measures as job modification or work practice changes, administrative changes, etc. A follow-up evaluation shall be scheduled in no less than three days whether the condition is worsened or unchanged. d) A protocol will be directed by a physican and followed by management which will allow sufficient time for the involved muscle/tendon/nerve group to heal. This shall include time off work, or transfer to another job which allows the affected muscle/tendon/nerve group to rest. When directed by a physician, employees shall be given sufficient time for the involved muscle/tendon/nerve group to heal. This time off work, or transfer to another job which allows the affected muscle/tendon/nerve group to rest. Employees shall be evaluated by a physician to assess their capability to return to work. Upon returning to work, they shall, when directed by a physician, be permitted to recondition the injured muscle/tendon/ nerve group by gradual resumption of duties. This should occur in addition to any other prescribed treatments. 4) Develop and implement a training program for the medical staff to include a detailed review of the medical aspects of CTD, and how to medically evaluate, treat, complete forms and reports, and to properly follow up. The training shall include recognition of plant job specific risk factors such as posture, force, repetition, vibration, contact nerve pressure, and cold. The additive effect of risk factors for CTD will be discussed along with an awareness of eliminating those which would aggravate the specific condition of an employee. Medical personnel, including consultant physicians, will be informed as necessary as to the availability of light duty jobs appropriate for an employee with a specific condition. 5) Develop and implement a training program for all supervisors and employees to enable them to recognize early symptoms, the need for proper medical care, and the need to ensure work activities are compatible with employees' physical conditions. 6) Conduct baseline health surveillance. The purpose of baseline health surveillance is to establish a base against which changes in health status can be evaluated. Workers being assigned to positions involving exposure of a particular body part to repeated biomechanical stress will receive baseline health surveillance. These positions will be identified from the data compiled in the catalog of standard job descriptions. The baseline health surveillance will include a medical and occupational history, and physical examination of the musculoskeletal and nervous systems as they relate to CTD. The examination should include, inspection, palpation, range of motion (active, passive and resisted) and other pertinent maneuvers of the upper extremities and back. Examples of the pertinent maneuvers for the hands and wrists include Tinel's test Phalen's test, and Finkelstein's test. Laboratory tests, x-rays and other diagnostic procedures are not a routine part of the baseline assessment. 7) Analyze light duty jobs for CTD potential. a) This written analysis shall include the procedures used in the performance of each job, including lifting requirements, postures, hand grips and frequency of repetitive motion. Such analysis shall be reduced to written form and provided to nurses, doctors and supervisory personnel involved in the assignment of light duty jobs. b) When an employee in a job not previously evaluated reports a CTD to medical personnel, that employee's actual performance of the job shall be evaluated to determine if ergonomic risk factors exist and corrective action is necessary for the work station and work method. 8) Develop a policy to inform employees that they will not be discriminated against because they reasonably request and visit the medical facilities or because they have diagnosed CTD problems and are undergoing medical rehabilitation. 9) Institute an exercise program emphasizing flexibility and stretching to help limit CTD's (two to five minute program to be "built in" to the workday on a periodic basis). 10) Institute hourly breaks from repetitive motion at a frequency of three to five minutes per hour. 11) Institute periodic safety and health meetings to encourage employees to discuss their medical concerns in a group setting. STEP 1- First Quarter A) Submit to the Area Director a written compliance program and plan of action outlining a schedule for the implementation of this medical program to identify and control CTDs. Quarterly progress reports updating this program and plan will be submitted to the Area Director until final abatement. B) Design the baseline symptoms survey and complete catalog of job activities. C) Assure employee protection against discrimination. STEP 2- Second Quarter A) Conduct a symptoms survey to identify CTD. B) Initiate quarterly records review to monitor CTD trends. C) Implement a medical management protocol. D) Implement medical supervisory and employee training. E) Initiate analysis of all light duty jobs. STEP 3- Third Quarter A) Initiate baseline health surveillance. B) Complete analysis of light duty jobs. STEP 4- Fourth Quarter A) Corrective action shall be completed by the implementation of all phases of this medical program.